People v. Daleon
REITERATIONFacts
The Antecedents: The accused, Antonio E. Daleon, was charged with malversation of public funds in Criminal Case No. 11723 before the Court of First Instance of Quezon. Procedural History: After trial, the court found the accused innocent of the charge, acquitted him, and ordered the payment of his salary during his suspension and his reinstatement. The Petition: The prosecution appealed the judgment, assigning as the sole error the trial court's order for the payment of the accused's salary during his suspension.
Issue(s)
Whether the trial court, in a criminal action for malversation of public funds wherein the accused is acquitted, has the power to order the payment of his salary during the period of his suspension. Whether an accused acquitted of malversation may claim back salaries and reinstatement in the same criminal case.
Ruling
The judgment appealed from is modified by eliminating therefrom that portion which orders the payment of appellee Antonio E. Daleon's salary during the period of his suspension from office. Costs against appellee Antonio E. Daleon.
Ratio Decidendi
On the issue of the trial court's power to order payment of salaries during suspension upon acquittal in a malversation case: The Supreme Court held that the trial court, in a criminal action for malversation of public funds where the accused is acquitted, is without power to order the payment of his salary during the period of his suspension. The Court reasoned that the only issue joined by a plea of not guilty is whether the accused committed the crime charged. Consequently, the only judgment the court is legally authorized to render is either one of acquittal or conviction, along with the corresponding civil indemnity and accessory penalties. The power to order payment of salaries during suspension is not within the scope of a criminal court's jurisdiction in such a scenario. The Court reiterated that the trial court's authority is limited to determining guilt or innocence and imposing penalties or ordering acquittal. The inclusion of an order for back salaries and reinstatement goes beyond the purview of the criminal proceedings. On the issue of whether an acquitted accused may claim back salaries and reinstatement in the same criminal case: The Supreme Court clarified that while an accused acquitted of malversation may indeed claim payment of back salaries during the period of suspension and reinstatement, such relief cannot be sought within the same criminal case where the acquittal occurred. The Court distinguished the present case from those cited by the appellee, explaining that the cited cases involved appeals from civil actions or administrative proceedings where such remedies were properly sought. Therefore, the proper recourse for an acquitted accused seeking back salaries and reinstatement is not the criminal case itself but a separate administrative or civil action prescribed by law. The Court emphasized that the criminal case is solely for the determination of criminal liability, not for the adjudication of administrative or civil claims arising from the suspension.
Main Doctrine
In a criminal action for malversation of public funds where the accused is acquitted, the trial court has no power to order the payment of his salary during the period of suspension; such relief must be sought in a separate administrative or civil action.